ML20045D109
| ML20045D109 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 01/31/2020 |
| From: | Holtec Decommissioning International |
| To: | Office of Nuclear Material Safety and Safeguards |
| Snyder A | |
| Shared Package | |
| ML20045D106 | List: |
| References | |
| Download: ML20045D109 (14) | |
Text
Holtec International, Inc.
Pilgrim Nuclear Power Station Upper ISFSI Physical Security Plan NRC Pre-Submittal Meeting January 31, 2020
www.holtec.com l Page 2 Oyster Creek Palisades Indian Point Topics:
1.Safety Topic 2.Introductions/Opening Remarks 3.Pilgrim ISFSI Project Overview 4.Approach for Physical Security Plan Revision for ISFSI Only 5.Exemptions and Exceptions to be Taken in the PSP 6.Closing Remarks
www.holtec.com l Page 3 Organization Andrea L. Sterdis - Holtec Decommissioning International Vice President Regulatory and Environmental Affairs J. Scott Thomson - Holtec Decommissioning International Executive Director of Global Security and Corporate Governance Officer Kevin Traver - Comprehensive Decommissioning International Pilgrim Security Training Supervisor Shawn Brust - Sargent and Lundy Security Program Manager Justin Corey - Sargent and Lundy Security Program Manager
www.holtec.com l Page 4 Pilgrim ISFSI Project Overview 4
- Existing ISFSI Pad and Fuel Loading Configuration:
- Fuel loaded to Existing ISFSI Pad
- Existing Pad located within current protected area
- Covered by current revision of Physical Security Plan
www.holtec.com l Page 5 Pilgrim ISFSI Project Overview 5
- Existing ISFSI Pad and Fuel Loading Configuration:
www.holtec.com l Page 6 Pilgrim ISFSI Project Overview 6
- Sequence governed in proposed revision to PSP
www.holtec.com l Page 7 Pilgrim ISFSI Project Overview 7
www.holtec.com l Page 8 Pilgrim ISFSI Project Overview 8
- Final Phase:
- New ISFSI to be standalone from rest of plant
- All casks located on New ISFSI Pad
- Governed by proposed PSP revision
www.holtec.com l Page 9 Pilgrim ISFSI Project Overview 9
- Final Phase:
www.holtec.com l Page 10 10 Pilgrim ISFSI Project Overview
- Timeline for Pilgrim Project Completion:
1st Quarter, 2020 Holtec Submits PSP to the NRC 4th Quarter, 2020 Completion of New ISFSI PA Construction 1st Quarter, 2021 NRC Acceptance of PSP Late 1st/Early 2nd Quarter, 2021 Start of Relocating Casks from Existing ISFSI to New ISFSI 2nd Quarter, 2021 Start of loading fuel from SFP to new ISFSI 1st Quarter, 2022 Final Cask Loaded to New ISFSI
www.holtec.com l Page 11 Approach to PSP Revision New ISFSI Requires a revision to the existing PSP Revision to consist of a separate Standalone ISFSI PSP included as an addendum to existing PSP Standalone ISFSI PSP is written in accordance with 10CFR73.55 with alternative measures Fuel Transfer to New ISFSI To be controlled under the stand alone ISFSI PSP Existing Plant including existing ISFSI and Spent Fuel Pool Remains controlled by existing PSP The revision will include minimal changes to note the new ISFSI PSP addendum 11
www.holtec.com l Page 12 New PSP Details New Alarm Stations ICAS (ISFSI Central Alarm Station) built within new PA Continuously manned Full video and annunciation of alarms ISAS (ISFSI Secondary Alarm Station) offsite monitoring facility MCI (Monitoring Controls Inc.)
Continuously manned Summary indication of alarm Communication with Existing Alarm Stations Redundant communication between ICAS and existing CAS/SAS operators New alarms and video in ICAS only, not routed to existing CAS/SAS 12
www.holtec.com l Page 13 Proposed Actions 10 CFR 73.55 Line Proposed position Proposed Change Justification Related Code Line 73.55(i)(2)
Alternative measure Central Alarm Station will have full video and annunciation of alarms however Secondary Alarm Station, which will be offsite, will have summary indication.
10CFR73.51 only requires one onsite Central Alarm Station and allows for a summary alarm indication at a Secondary Alarm Station N/A 73.55(i)(4)(iii)
Alternative measure Only the ISFSI Central Alarm Station (ICAS) will be located onsite, within protected area. ISFSI Secondary Alarm Station (ISAS) will be located offsite and non-redundant.
10CFR73.51 only requires one onsite Central Alarm Station and allows for a summary alarm indication at a Secondary Alarm Station N/A 73.55(a)(6)
Covered Under Alternative Measure Only the ISFSI Central Alarm Station (ICAS) will be located onsite, within protected area. ISFSI Secondary Alarm Station (ISAS) will be located offsite and non-redundant.
10CFR73.51 only requires one onsite Central Alarm Station and allows for a summary alarm indication at a Secondary Alarm Station 73.55(i)(4)(iii) 73.55(e)(7)(i)(B)
Covered Under Alternative Measure Isolation zone is monitored with intrusion detection equipment capable of detecting both attempted and actual penetration Only the ICAS satisfies 73.55(i) 10CFR73.51 only requires one onsite Central Alarm Station and allows for a summary alarm indication at a Secondary Alarm Station 73.55(i)(2) 73.55(e)(7)(i)(C)
Covered Under Alternative Measure Isolation zone is monitored with assessment equipment capable of providing real-time and play-back/recorded video images Only the ICAS satisfies 73.55(i) 10CFR73.51 only requires one onsite Central Alarm Station and allows for a summary alarm indication at a Secondary Alarm Station 73.55(i)(2) 73.55(e)(9)(v)(D)
Covered Under Alternative Measure Alternative measure is proposed for 73.55(i)(4)(iii) (as stated above), therefore, offsite ISAS will not be designated a vital area.
10CFR73.51 only requires one onsite Central Alarm Station and allows for a summary alarm indication at a Secondary Alarm Station 73.55(i)(4)(iii) 73.55(i)(4)(i)(A)
Covered Under Alternative Measure Alternative measure is proposed for 73.55(i)(2) (as stated above), therefore, offsite ISAS will only receive summary indication of alarms 10CFR73.51 only requires one onsite Central Alarm Station and allows for a summary alarm indication at a Secondary Alarm Station 73.55(i)(2) 73.55(b)(8)
Not Required No change Amendment No. 252 to Renewed Facility License No DPR-35 removes Cyber Security Plan form Pilgrim License Condition N/A 73.55(c)(6)
Not Required No change Amendment No. 252 to Renewed Facility License No DPR-35 removes Cyber Security Plan form Pilgrim License Condition N/A
www.holtec.com l Page 14 Questions?